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Question Answer Relevant links (if applicable)Additional comments
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NPOs' understanding of risk: What do NPOs understand by the risk of terrorist financing, how do they assess the risk of terrorist financing in the NPO sector and what is their assessment based on? What are the NPOs' views on the Federal Government's sectoral risk analysis?
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Risk mitigation measures: What measures and instruments do NPOs have in place to identify and mitigate risks?
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Government measures: Are the NGOs aware of the measures to combat terrorist financing? Are they considered effective? How does the government support NGOs?I suggest our talking point here be that the measures are effective at stopping TF but many of them unduly disrupt legitimate NPO work
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Regulation: Are the measures taken by the tax authorities considered sufficient? Are the government's measures proportionate and risk-based or are there restrictions on civil society organisations? Scope for action?We need to say that the Form 990 reporting is sufficient to ensure that NPOs aren't exploited for TF. At the same time, the IRS/tax code are being weaponized in ways that disrupt our work.
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Recommendations to the government: Some questions were aimed directly at the wishes and recommendations of the NPOs to the government. What can the government do better? What is important from the perspective of civil society?Ideas could include: find an honest broker to restart the multistakeholder dialogue; find a way to ensure that banks do not rely on internet gossip and smear campaigns for their due diligence, which leads to further derisking; stop weaponizing CFT framework to go after political enemies and protected speech;
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Problems in payment transactions/de-risking: The FATF sees de-risking as a major problem and refers to its new line of action to prevent unintended negative effects of the FATF recommendations on civil society. Spaces for action. How do NPOs assess the problem and what are possible solutions? Are there any known cases in which NPOs (have to) use alternative payment channels?Significant problem often delaying program implementation. Difficult to assess solutions given that banks are not public sector actors that can be influenced by usual channels of advocacy. Suggestions have included comfort letters from the government,
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How do you see the risk of NPOs being misused for TF?Low - we do our own due diligence to meet purposes of fulfilling our mission - we have no interest in our funds being misused.Austria FATF ME Onsite Meeting with NPO-representative in June 2026
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What do the internal risk assessments of NPOs look like? How are they done?Austria FATF ME Onsite Meeting with NPO-representative in June 2026
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How was the NGO sector’s involvement in the National Risk Assessment?Austria FATF ME Onsite Meeting with NPO-representative in June 2026
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How is your engagement with the banking sector?very difficult as a sector since the dissolution of the multistakeholder dialogueAustria FATF ME Onsite Meeting with NPO-representative in June 2026
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Has one of the NGOs been visited by tax authorities?Austria FATF ME Onsite Meeting with NPO-representative in June 2026
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What do you want from authorities? What could/should change?Austria FATF ME Onsite Meeting with NPO-representative in June 2026
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What are your TF threats/risks? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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Due Diligence and Controls: are these required by federal and local/state regulations? How do these hold up? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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Legal Requirements: are measures taken by the IRS in terms of tax and other requirements risk-based and appropriate? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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Sanctions & OFAC Obligations: How do NPOs work with OFAC? Are the relationships useful? Are they impactful? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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What role does FinCEN play? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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Relationships with Banks: What are the challenges in terms of opening bank accounts and what are the relationships like? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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What is your wish list if you could change anything in the regulations in the U.S.? U.S. FATF ME Onsite Meeting with NPOs-Assessors on 19 March 2026
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